Securities and Exchange Commission v. Nadel et al

Filing 1423

RESPONSE to Motion re 1419 Verified MOTION for miscellaneous relief, specifically to Authorize The Receiver to Retain a $100,000 Earnest Money Deposit Due to the Purchaser's Failure to Close the Court-Approved Sale of Quest Assets Memorandum of Points and Authority filed by Archer Petroleum. (Attachments: # 1 Appendix Index of Exhibits A-G, # 2 Exhibit A-Asset Purchase Agreement, # 3 Exhibit B-Email from Wiand, # 4 Exhibit C-Wire Transfer Receipts, # 5 Exhibit D-Emails Exchanged Wiand and Hudson, # 6 Exhibit E-Affidavit of Andrew Hudson, # 7 Exhibit F-Letter from Archer Petroleum to Wiand Cancelling Asset Purchase Agreement, # 8 Exhibit G-Order Granting Approval of Sale)(Krieger, Edwin)

Case 8:09-cv-00087-VMC-CPT Document 1419-4 Filed 10/03/19 Page 1 of 3 PageID 30445

EXHIBIT 4

Case 8:09-cv-00087-VMC-CPT Document 1419-4 Filed 10/03/19 Page 2 of 3 PageID 30446
Diane Burnette
From:
Sent:

Drew Hudson <[e-mail]>
Tuesday, June 25, 2019 4:50 PM
Burton Wiand
Jared Perez; Jeffrey Rizzo; Maya Lockwood; Roger Jernigan
Re: Quest closing

To:

Cc:

Subject:
Hi Burton,

Could we have a quick call tomorrow? Anytime works for me - let me know what's convenient for you
Thanks, Drew

Drew Hudson
214-701-8811
[e-mail]

Archer Petroleum Ltd.

PO Box 1544

McKinney, TX 75070
archerpetroleumltd.com
This email is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is
prohibited.
If you are not the intended recipient, please contact the sender by reply email and delete the original message.

On Sun, Jun 16, 2019 at 6:55 PM Burton Wiand <[e-mail]> wrote:
For sure
Burton W. Wiand
Wiand Guerra King, PA

813-347-5101 (0)
72 7-460-4679( C)

On Jun 16, 2019, at 4:25 PM, Drew Hudson <[e-mail]> wrote:
Thank you for the news. Could I get a confirmation of motion filing once that's filed and a copy?
Thanks,
Drew Hudson

214-701-8811
[e-mail]
Archer Petroleum Ltd.
PO Box 1544
McKinney, TX 75070
archerpetroleumltd.com
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Case 8:09-cv-00087-VMC-CPT Document 1419-4 Filed 10/03/19 Page 3 of 3 PageID 30447
This email is for the sole use of the intended recipient(s) and may contain confidential and privileged
information. Any unauthorized review, use, disclosure or distribution is prohibited.
If you are not the intended recipient, please contact the sender by reply email and delete the original
message.

From: Burton Wiand <[e-mail]>
Sent: Tuesday, June 11, 2019 7:52 PM
To: Drew Hudson
Subject: Re: Quest closing

Drew, today I reached agreement with the remaining creditors. That includes all taxing authorities so
you have no worries with respect to taxes. We hopefully will be filing the motion for approval this week
and look forward to a closing in the coming weeks. Thanks for your patience. BW
Burton W. Wiand
Wiand Guerra King PA
5505 W. Gray St
Tampa, FL 34609
813 347-5101
727 460-4679 (c)
On May 28, 2019, at 8:36 AM, Drew Hudson <[e-mail]> wrote:
Good morning,
Please let me know your anticipated timing of each remaining step towards closing:
motion filing, court order, notice period, close date, etc.
Thank you!
Drew Hudson
214-701-8811
[e-mail]
Archer Petroleum Ltd.
PO Box 1544
McKinney, TX 75070
archerpetroleumltd.com
This email is for the sole use of the intended recipient(s) and may contain confidential
and privileged information. Any unauthorized review, use, disclosure or distribution is
prohibited.
If you are not the intended recipient, please contact the sender by reply email and
delete the original message.

2